The Power Plugin - Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) explains how TPP GLOBAL LTD (“TPP”, “we”, “us”, or “our”) collects, uses, shares, and protects personal data in connection with our CRM and loyalty technology services (the “Services”) provided to Clients and, indirectly, to their end users (“Users”).

By using the Services, you acknowledge that your personal data may be processed in accordance with this Policy. This Policy applies to all Services provided through our platform, APIs, website(s), communications, and integrations.

2. Company Information

TPP GLOBAL LTD

24 Tax Suite, 137 B Westlink House 981

Great West Road, Brentford, TW8 9DN, United Kingdom

Company No.: 14954291

Email: giovanni@thepowerplugin.com

3. Roles & Responsibilities

Clients as Controllers: Our Clients are the data controllers for all personal data submitted to the platform via their systems, campaigns, or users.
TPP as Processor: We process personal data on behalf of our Clients under contractual obligations.
TPP as Controller: For data collected directly (e.g. through website forms, support, marketing), we act as the data controller.

4. Types of Personal Data Collected

We may collect and process the following data categories:

Client-provided data: names, emails, phone numbers, player IDs, participation history, addresses, birth dates, preferences, and points/reward balances.
Usage data: device information, IP address, browser metadata, location (if shared), page interactions.
Third-party data: information received from platforms, APIs, or tracking systems.
Cookies: used to improve UX and analytics (see section 11).

5. Lawful Basis for Processing

We process personal data under the following legal bases:

Contractual necessity – to deliver the Services requested by Clients.
Legitimate interest – for service improvement, fraud prevention, internal analytics.
Consent – where required (e.g. marketing or certain cookies).
Legal obligations – where applicable under law.

Clients are solely responsible for ensuring they have a valid legal basis to process their users’ personal data.

6. Use of Data

We use personal data for:

Operating and delivering CRM and reward fulfillment services
Powering API-based prize delivery systems
Tracking campaign and player performance
Personalizing user experiences
Customer support and maintenance
Product analytics and service improvement
Business intelligence and reporting
Legal and regulatory compliance

We do not create, operate or distribute gambling games. TPP is a service provider; compliance with gambling laws lies solely with the Client.

7. Data Retention

We retain personal data for as long as is necessary to:

Deliver Services to Clients
Comply with legal obligations
Resolve disputes or enforce agreements
Support business needs (limited to a reasonable period)

Upon request or contract termination, we delete or anonymize data in accordance with our data deletion policy.

8. Data Sharing & Transfers

We only share data under strict conditions:

Vetted subprocessors: such as logistics companies or analytics providers
Internal staff: only on a need-to-know basis, under NDA
Business transfers: in case of acquisition, merger or asset sale
Legal requirements: if required by law or regulation

Data may be transferred outside of the UK. When doing so, we implement Standard Contractual Clauses or other legally valid mechanisms to ensure protection.

9. Data Security

We implement industry-standard technical and organizational safeguards:

Encrypted communication & data storage
Access control and authentication protocols
Server and database hardening
Audit logs and anomaly detection
Backup and disaster recovery procedures

However, we cannot guarantee absolute security. Clients are responsible for securely managing their own access credentials and verifying user data accuracy.

10. User Rights (via Clients)

As per UK GDPR, Users may exercise the following rights (subject to local law):

Right to access data
Right to rectification
Right to erasure (“right to be forgotten”)
Right to restrict or object to processing
Right to data portability
Right to withdraw consent

When acting as processor, TPP will assist the Client in fulfilling such requests. Direct user requests will be referred to the appropriate Client.

11. Cookies and Tracking

We use cookies and similar technologies to:

Analyze website traffic and usage
Improve service performance
Enable session-based features

Users may opt out via browser settings. For non-essential cookies, we request consent via banner or settings interface.

12. Children’s Privacy

Our Services are not intended for minors. We do not knowingly collect personal data from individuals under 13 years of age (or applicable legal minimum). If discovered, such data will be promptly deleted.

Clients must ensure that players and end users meet the minimum legal age in their jurisdictions.

13. Data Breaches & Notifications

If a data breach affecting personal data occurs, we will:

Notify affected Clients within 72 hours of discovery
Cooperate in impact assessment and resolution
Support legal or regulatory notifications if applicable

14. Aggregated & Anonymized Data

We may use and share anonymized or aggregated data for statistical, research or commercial purposes, provided it does not identify individuals.

15. Third-Party Services

Our platform may link or integrate with third-party services. We are not responsible for their privacy practices. Users and Clients should review those third-party policies separately.

16. Business Transfers

If TPP is involved in a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction, under equivalent safeguards.

17. Limitation of Liability

TPP is not liable for:

Misuse or inaccuracy of data submitted by Clients
Use of our Services in violation of laws (gambling or otherwise)
Delays or errors caused by third-party infrastructure
Security incidents resulting from Client negligence

18. Policy Changes

We reserve the right to modify this Policy. Material updates will be communicated via email or platform. Continued use of the Services implies acceptance of the revised Policy.

19. Contact

For questions or concerns about this Privacy Policy or your data: